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Violation#106: Failed to train employees on waste handling and emergency procedures. Observation:At the time of the inspection, it could not be demonstrated (not necessarily documented)that employees who handle hazardous waste were properly trained, based on the violations observed at the time of inspection. Banfield Response:As outlined in Banfield's Waste Management Plan, all Banfield hospitals are required to train hospital personnel on proper waste handling and emergency procedures relevant to their responsibilities, and all personnel at Hospital #1164 completed online training on how to properly manage hazardous waste. Documentation is provided in Attachment D.Additionally, Banfield's HSE department's waste management consultant(Bridge House Advisors) hosted a call with the current hospital manager to review the Waste Management Plan and answer any questions.The manager reviewed hazardous waste requirements with hospital personnel during the weekly safety meeting on 1 April 2020. A copy of the attendance log from the most recent safety meeting, as well as logs from the original online training, are included in Attachment D. Violation#108: Failed to complete, sign or date manifest; or obtain dated signature of transporter. Observation: Failed to complete, sign or date manifest; or obtain dated signature of transporter. 1. Uniform Hazardous Waste Manifest(UHWM) 000945558WAS with shipment date 4/2/2019 incorrectly lists waste code P042. 2. UHWM 000945923WAS with shipment date 8/19/20129 incorrectly lists waste code P042. Banfield Response: Banfield hospitals do not generate epinephrine waste that is a P-listed waste, as the drug is manufactured from an epinephrine salt. As indicated in the HW Inspection Amended Report, this violation was corrected on 12/18/2019 by Sean Akers, Banfield HSE Specialist, by submittal of a correction to the Department of Toxic Substances. No further action was required. Violation#110: Failed to keep signed copy of manifests from the designated facility for three years. Observation: Designated facility signed copies of the following Uniform Hazardous Waste Manifest (UHWM) numbers were not found on-site: - 009149120FLE (9/5/2017) (see photo IMG 9720) - 010176114FLE (2/28/2018) (generator copy also not found on site) - 012121262FLE (10/24/2018) (generator copy also not found on site) - 012121379FLE (11/28/2018) (generator copy also not found on site) Banfield Response:As outlined in Banfield's Waste Management Plan, all Banfield hospitals are required to maintain the signed designated facility manifests with the plan. However, all manifests are tracked on the hazardous waste vendor's website (Sharps Tracer [formerly Stericycle]). For the four manifests in question, each shipment of waste was received at the designated facility within the 35-day timeframe. Please see Attachment E for signed copies of the manifests from the designated facility. Violation#111: Failed to comply with uniform hazardous waste manifest exception requirements. Observation:The facility did not have exception reports on site for the following UHWMs: - 009149120FLE (9/5/2017) (see photo IMG 9720) - 010176114FLE (2/28/2018) (generator copy also not found on site) - 012121262FLE (10/24/2018) (generator copy also not found on site) - 012121379FLE (11/28/2018) (generator copy also not found on site) Banfield Response: See the response to Violation#110, above.All manifests were received within the 35-day timeframe;thus, no exception documentation was required.As outlined in Banfield's Waste Management Plan, if the final manifest copy is not received from the disposal facility within 30 days of waste pickup,the hospital is to contact the HSE team who will determine the final disposition of the waste and file the appropriate exception report documentation, if needed.